SecProbe.io

Mail Stop 3561

October 16, 2015

Mohawk Industries, Inc.
Frank H. Boykin
Chief Financial Officer
160 S. Industrial Blvd.
Calhoun, Georgia  30701

Re: Mohawk Industries, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2014
Filed February 27, 2015
Response dated September 17, 2015
File No. 1-13697

Dear Mr. Boykin :

We have reviewed  your September  17, 2015 response to our comment letter and have the
following comment s.  In our comment s, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to these comment s within ten busine ss days by providing t he requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comment s apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comment s, we may have  additional comments.
Unless we note otherwise, our references to prior comments are to comments in our August 20,
2015 letter .

Form 10 -K for the Fiscal Year Ended December 31, 2014

Item 7. Management’s Discussion and Analysis of Financial Co ndition and Results of
Operations

Year Ended December 31, 2014, as Compared with Year Ended December 31, 2013

Gross Profit, page 22

1. We note your response to comment 2.  Please refer to your discussion of the factors
impacting changes in cost of sales within your operating income section and explain to us
in further detail how your discussion captures the significant components of cost of sales,
such as material, labor and other applicable expenses.   Further, we note your discussion

Frank H. Boykin
Mohawk Industries, Inc.
October 16 , 2015
Page 2

 of higher input costs impacting your operating income and have read the prepared
remarks from your first quarter 2015 earnings transcript which included a st atement  that
“raw material costs were higher than in the same period last year.”  If higher input costs
are reasonably expected to affect your future results , we believe you should highlight, to
the extent applicable, whether such movements  are expected to  cause future results to
differ from historical results.  Please also tell us and revise your disclosures to define the
term “operations productivity” and clarify how you calculate the amounts disclosed in
your gross profit and operating income discussions .  Refer to Item 303(A)(3)(ii)  of
Regulation S -K.

Income tax expense, page 23

2. We note your response to comment 4.  Although we believe that your proposed
disclosure revision s will be useful to investors, it appears that additional disclosures
should be provided to highlight the impact that the geographical mix of your income had
on your income tax expense and effective tax rate.  We note that foreign earnings before
income tax es increased by over 100% from fiscal 2013 to 2014, whereas the respective
domestic increase was only 15%.  Considering your foreign effective tax rate appears to
have fluctuated between approximately (3%) and (10%) during the annual periods
presented and your domestic effective tax rate fluctuated between approximately 33%
and 43%, we believe that a cross -reference to your income tax footnote does not
adequately explain the movements in your income tax expense or effective tax rates.
Accordingly, please c onsider revising  your discussion to separately explain  the reasons
for fluctuations in your domestic and foreign effective tax rates , to quantify your
domestic and foreign effective tax rates , and to quantify the impact of the geographical
mix of your inco me on your income tax expenses and effective tax rates.

Item 8. Consolidated Financial Statements and Supplementary Data

(16) Commitments and Contingencies, page 66

3. We have reviewed your response to comment 10 and note that you settled your U.S.
antitrust case within a month after your Form 10 -K filing date.  Please expand on the
reasons why you were unable to estimate the amount  of loss  or range of loss for this case
as of your Form 10 -K filing date.  In doing so, please provide us with a sufficiently
detailed background of the settlement negotiations, including when they were initiated
and the party that initiated the process .

Frank H. Boykin
Mohawk Industries, Inc.
October 16 , 2015
Page 3

 You may contact Robert Babula, Staff Accountant at  (202) 551 -3339  or Andrew Blume,
Staff Accountant at (202) 551 -3254  if you have questions regarding our comment s on the
financial statements and related matters.  Please contact  me at (202) 551 -3737  with an y other
questions.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief
Office of Consumer Products